Construction Waste Management Plan
Construction Waste Management Plan
Construction Waste Management Plan
CONSTRUCTION
WASTE MANAGEMENT PLAN
FOR
RELATING TO A PROPOSED
AT
DEER PARK
HOWTH
CO. DUBLIN
1.0 INTRODUCTION 2
The proposed application area is greenfield and is enclosed along its northern and
eastern boundaries by a demesne wall. To the south is Deer Park golfclub and to the
west residential dwellings.
A review of historical aerial photography identifies that other than partial use as a
racetrack, which use ceased in 1842, the site has been in its present condition i.e.
greenfield.
The CWMP has been prepared to demonstrate how the Construction Phase will comply
with the following relevant legislation and relevant Best Practice Guidelines:
Waste Management (Collection Permit) Regulations 2007 (SI No. 820 of 2007)
EPA “Guidance on Soil and Stone By-Products in the context of Article 27 of the
European Communities (Waste Directive) Regulations – Version 3 June 2019
Fingal County Council Development Plan 2017 – 2023 – Construction & Demolition
Waste Management Objectives
The CWMP shall be implemented throughout the construction phase of the development
to ensure the following:
Demolition
To facilitate access to the development, it is proposed to provide a vehicular and
pedestrian access to the northwest of the site and a separate pedestrian access to the
north east. This will necessitate partial demolition of the northern demesne boundary
wall. This is the only demolition required to facilitate the development.
The project conservation architect describes the wall as comprising coursed random
rubble construction mainly Calp limestone, the upper section which has been rebuilt and
repointed. The masonry construction is generally limestone laid and originally pointed
with a non-hydraulic lime mortar mix. The evidence of later rebuilding can be seen by the
variation in stone and workmanship.
The method statement for the works proposed to the wall is included as an Appendix to
the Construction Environmental Management Plan prepared by Barrett Mahony
Consulting Engineers included under separate cover.
There are no other structures present on site and accordingly this report deals with
waste arising from the construction phase of the proposed development.
Construction Phase
The range of works required for the Construction Phases are summarised in Table 1.
The expected construction and demolition waste that will be generated throughout the
course of the development are described in Tables 2 - 4 below.
Description of Waste %
➢ Objectives for the Project including the potential to re-use existing on-site materials
for further use in the construction phase.
➢ Waste Auditing
➢ Record Keeping
The Project Manager will be responsible for the overall implementation of the CDWMP.
The Project Manager will ensure that the reporting and recording requirements are met
and all necessary resources are in place to support the implementation of the plan.
A technically competent and appropriately trained C&D Waste Officer will be appointed
by the Project Manager. The nominated person will be responsible for all aspects waste
management throughout the different stages of the project including waste assessment
8
A key objective of the nominated person will be the maintenance of accurate records on
the quantities of waste / surplus materials generation and management. The recording of
summary information will further assist the implementation of the plan.
➢ It is proposed that from the outset of construction activities, a dedicated and secure
compound containing bins, and/or skips, and storage areas, into which all waste
materials generated by construction site activities, will be established within the active
construction phase of the development site.
➢ Spill kits shall be located within the waste compound with clearly labelled instructions
on how they shall be used to clean up fuel/oil spills.
➢ All vehicle and plant oils and liquid construction materials shall be stored in
impermeable storage units.
➢ All empty containers containing residual quantities of oils, greases and hydrocarbon-
based liquids shall be stored in a dedicated bunded receptacle in the waste
compound.
➢ It is the responsibility of the C&D waste officer that all contracted waste haulage
drivers hold an appropriate Waste Collection Permit for the transport of waste loads
and that all waste materials are delivered to an appropriately licenced or permitted
waste facility in compliance with the following relevant Regulations:
Waste Management (Collection Permit) Regulations 2007 (SI No. 820 of 2007)
Waste Management (Collection Permit) Amendment Regulations 2008 (SI No. 87 of
2008)
➢ It is proposed that waste materials will be collected and stored in separate clearly
labelled skips in a predefined waste storage area in the site compound and that these
materials will be collected by a Permitted Waste Contractor holding an appropriate
Waste Collection permit in compliance with Waste Management (Collection Permit)
Regulations 2007 (SI No. 820 of 2007) and Waste Management (Collection Permit)
Amendment Regulations 2008 (SI No. 87 of 2008) and that they will be sent for
disposal or further processing to appropriately Permitted / Licensed Waste Facilities
in compliance with Waste Management (Facility Permit and Registration) Regulations
S.I. No. 821 of 2007 and the Waste Management (Facility Permit and Registration)
Amendment Regulations S.I. No. 86 of 2008.
➢ Prior to the commencement of the Project, the C&D waste officer shall identify a
permitted Waste Contractor who shall be employed to collect and dispose of all inert
and hazardous wastes arising from the project works. In addition, the C&D waste
manager shall identify all waste licensed / permitted facilities that will accept all
expected waste exported off-site and will maintain copies of all relevant Waste
Permits / Licences as required.
➢ All waste soils prior to being exported off-site, shall be classified as inert, non-
hazardous or hazardous in accordance with the EPA’s Waste Classification Guidance
– List of Waste & Determining if Waste is Hazardous or Non-Hazardous document
dated 1st June 2015 to ensure that the waste material is transferred by an
appropriately permitted waste collection permit holder and brought to an appropriately
permitted or licensed waste facility.
A dedicated and secure construction waste storage compound shall be located adjacent
to the site offices. The C&D Waste Manager shall be responsible for the management of
the construction waste compound. The area shall be demarcated by fencing and shall be
of sufficient size to house a minimum of 4 x 20 cubic yard roll on roll off skips for
construction waste materials and 1 x 14 cubic yard covered skip for mixed municipal
wastes generated by site staff.
All subcontractors shall be instructed by the C&D Waste Officer to remove their waste
off-site from their work areas on a daily basis
Signage shall be installed at each skip to clearly identify the nature of waste that may be
placed within it.
10
Individual construction waste skips shall accommodate waste wood, metal, plastics,
gypsum products.
Figure 3 Oil Spill Kit Figure 4 Bund for waste oil container storage
11
Waste will arise on the project mainly from bulk excavation and general construction
activities and site infrastructure construction. The site management team will order
materials and arrange storage in order to minimise the potential for waste on site.
➢ All staff and Sub contractors shall be advised through tool box talks on how to
dispose of their waste correctly on-site.
➢ Sub-Contractors will be instructed to remove off-site all waste generated from their
activities on a daily basis.
➢ Concrete blocks, engineering bricks and clay bricks that are surplus will be broken up
and used for hardstanding areas.
➢ Excess wood will be segregated in separate skips and sent for recycling. The site
management will police to make sure that the segregation of the wood skip is kept
exclusively for wood.
➢ Plastic arising from general waste or packaging will be segregated and stored in
separate skips. Again, the site management team will ensure that there is no
contamination of the segregated skips on site.
➢ Top soil that is required for the soft landscaping will be measured and this quantity
will be retained on site. The soil that will have to be removed off site will be removed
to a licenced landfill facility. The C&D Waste Manager. will keep records of the
removal and the certification on file on site.
➢ Any hazardous material discovered during the course of the construction shall be
reported to the C&D Waste Manager. The relevant authorities will be informed and an
agreed method for the removal of the hazardous material.
12
The Project Engineers, Barret Mahony Consulting Engineers, have estimated that c.
30,000m3 of soils will be excavated to depths between 4.5m – 7m to facilitate the
development and exported from the site.
Soils at the site have been classified following WAC testing by Ground Investigations
Ireland and the completion of a Waste Classification Assessment. The Waste
Classification Report & Subsoil Assessment is included as Appendix III to this report.
The scope of the work undertaken to facilitate the waste classification exercise included
the following:
In order to assess materials, which may be excavated from site, in terms of waste
classification, a selection of samples collected were analysed for a suite of parameters
which allows for the assessment of the soils in terms of total pollutant content for
classification of materials as hazardous or non-hazardous (RILTA Suite). The suite also
allows for the assessment of the soils in terms of suitability for placement at various
categories of landfill.
In total, thirty (30 No.) samples were assessed using the HazWasteOnLineTM Tool. The
location of the trial pits are illustrated in the Figure below.
13
The assessment concluded that on-site soils are classified with LoW Code 17 05 04 may
be classified as non-hazardous and are defined as a Category A Criteria as follows. Soil
and Stone only which are free from anthropogenic materials such as concrete and
timber. Soils must be free from “contamination” e.g. PAH’s, Hydrocarbons and Asbestos.
Category A material can be disposed/recovered at unlined soil recovery facilities.
Based on the WAC analysis, it is intended to declare the excavated soils a by-product to
the EPA in accordance with Article 27 of the European Communities (Waste Directive)
Regulations 2011 and the EPA publication “Guidance on Soil and Stone By-Products in
the context of Article 27 of the European Communities (Waste Directive) Regulations –
Version 3 June 2019.
14
Based on the type of material to be excavated i.e. virgin soils, the fact that it is being
excavated to facilitate the proposed development and the results of the WAC analysis,
conditions 2-4 above are met.
Regarding Condition 1, at this stage, it is too early to identify a specific site where the
material would be used. This is because, it is necessary first to secure planning
permission to have certainty regarding the availability of the by-product and only then
can a further use be identified. However, having regard to the scale of development
taking place in Dublin, it is reasonably expected that there will be projects seeking to
avail of this by-product. The selected location will be identified in the notification to the
EPA.
Having regard to the WAC analysis, it is deemed unlikely that the excavated soils would
be rejected by the EPA as a by-product. Notwithstanding, should this situation arise the
excess soils would be exported for authorised recovery. All construction waste and soils
will only be exported to authorised waste facilities holding a valid Waste Licence, Waste
Facility Permit or a Certificate of Registration.
Construction waste material will be exported of site by the following permitted waste
collection contractors and shall be transferred to the following facilities:
15
It is the responsibility of the C&D Waste Officer that a written record of all quantities and
natures of all wastes reused / recycled and exported off-site during the project are
maintained in a Waste File at the Project office.
The following information shall be recorded for each load of waste exported off-site:
The waste records shall be issued to Fingal County Council as required / requested.
Where practicable, a computerised monitoring tool may be employed. This system will
enable the Contractor to measure and record the quantity of waste generated, and
identify possible savings on wastage. Thus, each consignment of C&D waste taken from
site will be subject to documentation and recording. An indicative template is contained
in Appendix II to ensure that full traceability of materials to its final destination.
Verifiable and validated tracking and authorisation documentation will be maintained for
all wastes destined for re-use, recovery, recycling or disposal. Justification will also be
provided where a disposal option had been employed.
16
The effectiveness of a Waste Management Plan (WMP) and its implementation, will be
subject to regular audits by the C&D Waste Officer throughout the duration of the project
in accordance with the Audit Plan (to be developed during the works).
The regular audits will focus on materials inputs to the project and the waste outputs for
each operation identifying additional opportunities for waste reduction, re-use and
recycling.
The audits will also investigate the operational factors and management policies that
contribute to the generation of waste and identify appropriate corrective actions, where
necessary.
Performance targets will be developed, e.g. an 85% overall recycling target, successes
and failures will be recorded and Action Plans will be developed to address any issue
which arise.
Inspections of the waste storage areas will be undertaken on a weekly basis, issues
relating to housekeeping, inappropriate storage and / or segregation will be actioned at
the earliest practicable opportunity.
The C&D Waste Officer will record the findings of the audits, including waste types
identified, quantities of waste arising, final treatments and cost, in a report to be available
to the Local Authority as required during the course of the works.
Details of the inputs of materials to the construction site and the outputs of wastage
arising from the project will be investigated and recorded in the Final Waste Audit, which
will identify the amount, nature and composition of the waste generated on the site.
The Final Waste Audit will examine the manner in which the waste is produced and will
provide a commentary highlighting how management policies and practices may
inherently contribute to the production of construction and demolition waste.
The measure waste quantities will be used to qualify the costs of management and
disposal in a Waste Audit Report, which will also record lessons learned from these
experiences, which can be applied to future projects.
It is the responsibility of the C&D Waste Officer that a written record of all quantities and
natures of all wastes reused / recycled and exported off-site during the project are
maintained in a Waste File at the Project office.
The groundworks contractor will be responsible for the excavation of soils and their
subsequent transport off-site to a permitted waste acceptance facility.
17
The groundworks contractor’s vehicles shall transport waste materials from the site to
appropriately permitted / licenced facilities.
Copies of all relevant Waste Collection Permits and Waste Facility Permits / Waste
Licences shall be maintained by the C&D Waste Officer and are detailed below in
Appendix I.
All monthly waste logs shall include the gate receipt from the facility accepting the waste
load. This receipt shall correspond with the load removed from site.
18
19
Soil and Stones 17 05 04 17 05 04 Soils and Stones other than those mentioned in 17 05 03
17 01 07 Mixture of concrete, bricks, tiles and ceramics other than those mentioned in 17 01 06
17 01 01 Concrete
17 01 02 Brick
17 01 03 Tiles and Ceramics
13 02 08* Engine, gear and lubricating oils
16 01 07 Ferrous Metal
17 02 02 Glass
17 02 03 Plastic
17 04 07 Mixed Metals
17 08 02 Gypsum based construction materials
NOTE This list is not final and shall be expanded as wastes are generated
Howth Road
January 2020
DOCUMENT CONTROL SHEET
Project No 9298-12-19
Ground Investigations Ireland Ltd. present the results of the fieldworks and laboratory testing in accordance with the specification and
related documents provided by or on behalf of the client. The possibility of variation in the ground and/or groundwater conditions
between or below exploratory locations or due to the investigation techniques employed must be taken into account when this report
and the appendices inform designs or decisions where such variation may be considered relevant. Ground and/or groundwater
conditions may vary due to seasonal, man-made or other activities not apparent during the fieldworks and no responsibility can be
taken for such variation. The data presented and the recommendations included in this report and associated appendices are intended
for the use of the client and the client’s geotechnical representative only and any duty of care to others is excluded unless approved
in writing.
CONTENTS
1.0 Preamble............................................................................................................................................ 5
2.0 Purpose & Scope .............................................................................................................................. 5
3.0 Limitations......................................................................................................................................... 5
4.0 Site Location and Layout ................................................................................................................. 6
5.0 Site History ........................................................................................................................................ 6
6.0 Subsurface Exploration ................................................................................................................... 6
6.1. General .............................................................................................................................................. 6
6.2. Trial Pits............................................................................................................................................. 7
7.0 Ground Conditions ........................................................................................................................... 7
7.1. General .............................................................................................................................................. 7
7.2. Groundwater ..................................................................................................................................... 7
7.3. Laboratory Testing ........................................................................................................................... 8
8.0 Asbestos............................................................................................................................................ 8
9.0 Waste Classification ......................................................................................................................... 8
10.0 HazWasteOnLineTM Results ........................................................................................................... 10
11.0 Landfill Waste Acceptance Criteria .............................................................................................. 11
12.0 Final Waste Categorisation ........................................................................................................... 12
13.0 By-Product Suitability .................................................................................................................... 13
14.0 Conclusions & Recommendations ............................................................................................... 14
14.1. Conclusions .................................................................................................................................... 14
14.1.1. Waste Classification ............................................................................................................... 14
14.1.2. Waste Categories .................................................................................................................... 14
14.1.3. Asbestos .................................................................................................................................. 14
14.1.4. By-Product Suitability ............................................................................................................. 14
14.2. Recommendations ......................................................................................................................... 14
14.2.1. Waste Transfer ........................................................................................................................ 14
14.2.2. Removal of Material as a By-Product .................................................................................... 15
15.0 References ...................................................................................................................................... 16
LIST OF TABLES
APPENDICES
Appendix 1 Figures
Appendix 2 Trial Pit Records
Appendix 3 Laboratory Testing
Appendix 4 HazWasteOnLineTM Report
Appendix 5 WAC Data Summary
Appendix 6 Suitable 4 Use Data
Appendix 7 Potential Material Outlets
GII Waste Classification Report January 2020 Waste Classification Report
1.0 Preamble
Ground Investigations Ireland (GII) was appointed by Barrett Mahony Consulting Engineers (BMCE) on
behalf of Glenveagh Properties PLC (Glenveagh) to carry out a Waste Classification and Subsoil
Assessment for a proposed residential development in Howth, Dublin 13. All site investigation works were
carried out under the supervision of a GII Geo-Environmental Engineer. The site investigation works were
completed in December 2019.
It is understood that as part of the proposed development there will an excavation to accommodate a
basement structure and as such the material which may be excavated and removed from site needs to be
assessed in terms of waste disposal outlets or re use.
The purpose of the waste classification subsoil assessment exercise was as follows.
Classification, in terms of waste management and final disposal outlets, of material that may require
disposal following excavation during the construction phase; and
Assess the materials suitability in terms of subsoil quality and potential environmental impact for
removal from site as a by-product.
The scope of the work undertaken to facilitate the waste classification exercise included the following:
3.0 Limitations
GII has prepared this report for the sole use of Glenveagh. No other warranty, express or implied, is made
as to the professional advice included in this report or other services provided by GII.
The conclusions and recommendations contained in this report are based upon information provided by
others and the assumption that all relevant information has been provided by those bodies from whom it
has been requested. Information obtained from third parties has not been independently verified by GII,
unless otherwise stated in this report.
This report has been prepared in line with best industry standards and within the project’s budgetary and
time constraints. The methodology adopted and the sources of information used by GII in providing its
services are outlined in this report.
The work described was undertaken in December 2019, this report is based on the conditions encountered
and the information available during that period. The scope of this Report and the services are accordingly
factually limited by these circumstances.
GII disclaim any undertaking or obligation to advise any person of any change in any matter affecting the
Report, which may come or be brought to GII’s attention after the date of the Report.
The conclusions presented in this report represent GII’s best professional judgement based on review of
site conditions observed during any site visit and the relevant information available at the time of writing.
The opinions and conclusions presented are valid only to the extent that the information provided was
accurate and complete.
The investigation was focused on a broad assessment of the subsoil quality across the site. The
assessment did not extend to the identification of asbestos containing materials associated with any on-
site structures, ground gases or groundwater.
The waste classification exercise is reflective of and applicable to the ground conditions on site at the time
of the site investigation and sampling. Alterations to the ground conditions or any further excavations carried
out on site following the investigation are not reflected in this report.
The site is located on the southern side of Howth Road between Sutton Village and Howth Village (Figure
1 Appendix 1). At the time of the assessment the site was an open grassed field and was not in use. The
lands to the south and east were occupied by a golf course. The site is bounded to the north by the Howth
Road and housing to the west.
GII reviewed the aerial photographs and historical maps maintained by the Ordnance Survey of Ireland
(OSI) and the google imagery records (Figure 2 to 4). These included the 6-inch maps that were produced
between 1829 and 1842, the 25-inch maps that were produced between 1888 and 1913 and the 6-inch
Cassini Maps that were produced between the 1830’s and 1930’s. The site is undeveloped on all historical
maps. The site is in its current use on all reviewed historical aerial photographs.
6.1. General
During the ground investigation a programme of intrusive investigation specified by the Consulting Engineer
was undertaken to determine the sub surface conditions at the proposed site. Regular sampling and in-
situ testing was undertaken in the exploratory holes to facilitate the geotechnical descriptions and to enable
laboratory testing to be carried out on the soil samples recovered during excavation and drilling.
The procedures used in this site investigation are in accordance with Eurocode 7 Part 2: Ground
Investigation and testing (ISEN 1997 – 2:2007) and B.S. 5930:2015.
The trial pits were excavated using a JCB 3CX excavator at the locations shown in Figure 5. The locations
were checked using a CAT scan to minimise the potential for encountering services during the excavation.
The trial pits were sampled, logged and photographed by a Geotechnical Engineer/Engineering Geologist
prior to backfilling with arisings. Notes were made of any services, inclusions, pit stability, groundwater
encountered and the characteristics of the strata encountered and are presented on the trial pit logs which
are provided in Appendix 2 of this Report.
7.1. General
The ground conditions encountered during the investigation are summarised below with reference to insitu
and laboratory test results. The full details of the strata encountered during the ground investigation are
provided in the exploratory hole logs included in the appendices of this report.
The sequence of strata encountered were consistent across the site and are generally comprised;
Topsoil
Cohesive Deposits
TOPSOIL: Topsoil was encountered in all the exploratory holes and was present to a maximum depth of
0.4m BGL.
COHESIVE DEPOSITS: Cohesive deposits were encountered beneath the Topsoil and were described
typically as brown slightly sandy slightly gravelly CLAY with occasional subangular to subrounded cobbles.
The secondary sand and gravel constituents varied across the site and with depth, with granular lenses
occasionally present in the glacial till matrix. These deposits had some, occasional or frequent cobble and
boulder content where noted on the exploratory hole logs.
7.2. Groundwater
Groundwater was encountered in three locations TP-01, 05 and 12 at depths of 2.8m, 3.0m and 3.2m BGL
respectively. The recorded groundwater inflows were minor. It should be noted that these exploratory holes
did not remain open for sufficiently long periods of time to establish the hydrogeological regime and
groundwater levels would be expected to vary with the time of year, rainfall, nearby construction and other
factors.
In order to assess materials, which may be excavated from site, in terms of waste classification, a selection
of samples collected were analysed for a suite of parameters which allows for the assessment of the soils
in terms of total pollutant content for classification of materials as hazardous or non-hazardous (RILTA
Suite). The suite also allows for the assessment of the soils in terms of suitability for placement at various
categories of landfill. The parameter list for the RILTA suite includes analysis of the solid samples for
arsenic, barium, cadmium, chromium, copper, cyanide, lead, nickel, mercury, zinc, speciated aliphatic and
aromatic petroleum hydrocarbons, pH, sulphate, sulphide, moisture content, soil organic matter and an
asbestos screen.
The RILTA suite also includes those parameters specified in the EU Council Decision establishing criteria
for the acceptance of waste at Landfills (Council Decision 2003/33/EC), which for the solid samples are pH,
total organic carbon (TOC), speciated aliphatic and aromatic petroleum hydrocarbons, BTEX, phenol,
polychlorinated biphenyls (PCB) and PAH.
In line with the requirement of Council Decision 2003/33/EC a leachate was generated from the solid
samples which was in turn analysed for antimony, arsenic, barium, cadmium, chromium, copper, lead,
mercury, molybdenum, nickel, selenium, zinc, chloride, fluoride, soluble sulphate, sulphide, phenols,
dissolved organic carbon (DOC) and total dissolved solids (TDS). The suite was selected due to no
evidence of specific contaminants of concern highlighted in the site history. The laboratory testing was
competed by Element Materials Technology (EMT) in the UK; EMT is a UKAS accredited laboratory. The
full laboratory report is included in Appendix 3.
8.0 Asbestos
Asbestos fibres were not detected in the samples. The laboratory did not identify asbestos containing
materials (ACMs) in the samples.
GII understands that any materials which may be excavated from site would meet the definition of waste
under the Waste Framework Directive. This may not be the case at the time of excavation when all or some
of the materials may have been declared a by-product in line with Article 27 of the European Communities
(Waste Directive) Regulations 20111.
Excess soil and stone resulting from excavation works (the primary purpose of which is not the production
of soil and stone) may be declared a by-product if all four by-product conditions are met.2
1
S.I. No. 126/2011 - European Communities (Waste Directive) Regulations 2011 (Article 27).
2
Irish EPA (June 2019), Guidance on Soil and Stone By-Products.
b) the soil and stone can be used directly without any further processing other than normal industrial
practice;
c) the soil and stone is produced as an integral part of a production process; and
d) further use is lawful in that the soil and stone fulfils all relevant requirements for the specific use
and will not lead to overall adverse environmental or human health impacts.
Due to the varying levels of anthropogenic materials encountered in the made ground there are potentially
two sets of List of Waste (LoW)3 codes with “mirror” entries which may be applied to excavated materials
to be removed from site.
1. 17-05-03* (soil and stone containing dangerous substances, classified as hazardous) or 17-05-04
(soil and stone other than those mentioned in 17-05-03, not hazardous); or
2. 17-09-03* (other construction and demolition wastes (including mixed wastes) containing
hazardous substances) or 17-09-04 (mixed construction and demolition wastes other than those
mentioned in 17 09 01, 17 09 02 and 17 09 03).
Where waste is a mirror entry in the LoW, it can be classified via a process of analysis against standard
criteria set out in the Waste Framework Directive. The assessment process is described in detail in
guidance published by the Irish (EPA Waste Classification, List of Waste & Determining if Waste is
Hazardous or Non-Hazardous, June 2015) and UK regulatory authorities (Guidance on the Classification
and Assessment of Waste: Technical Guidance WM3, 2015). The assessment involves comparison of the
concentration of various parameters against defined threshold values.
The specific LoW code which should be applied to the material at each sample location is summarised in
Table 1 below. These codes are only applicable where the material is being removed for site as a waste.
GII use HazWasteOnlineTM, a web-based commercial waste classification software tool which assists in the
classification of potentially hazardous materials. This tool was used to determine whether the materials
sampled are classified as hazardous or non-hazardous. The use of the online tool is accepted by the EPA
(EPA 2014).
The conclusions presented in the report are based on GII’s professional opinion. It should be noted that
the environmental regulator (in this case the EPA) and the waste acceptor (in this case a landfill
operator) shall decide whether a waste is hazardous or non-hazardous and suitable for disposal at
their facility.
3
Formerly European Waste Catalogue Codes (EWC Codes)
In total, thirty (30 No.) samples were assessed using the HazWasteOnLineTM Tool. All samples were
classified as being non-hazardous. The complete HazWasteOnLineTM report for all samples is included in
Appendix 4.
The specific LoW code which should be applied to the material at each SI location is summarised in Table
1 below. The assigning of the LoW code is based on observations recorded in the trial pits, an estimation
of the % of anthropogenic material present and the results of the HazWasteOnlineTM output. The final LoW
codes applied at the time of disposal may vary due to variations in % of anthropogenic material observed
in the excavation phase. Where there is in excess of 2%4 anthropogenic material observed the LoW code
17 09 04 may be applied.
4
EPA (2017) - Draft Guidance Note on Soil Recovery Waste Acceptance Criteria.
5
NAD – no asbestos detected.
Waste Acceptance Criteria (WAC) have been agreed by the EU (Council Decision 2003/33/EC) and are
only applicable to material if it is to be disposed of as a waste at a landfill facility. Each individual member
state and licensed operators of landfills may apply more stringent WAC. WAC limits and the associated
laboratory analysis are not suitable for use in the determination of whether a waste is hazardous or non-
hazardous. The data have been compared to the WAC limits set out in Council Decision 2003/33/EC as
well as the specific WAC which the EPA have applied to the Integrated Materials Solutions (IMS) Landfill
in north County Dublin. The IMS landfill has higher limits for a range of parameters while still operating
under an inert landfill licence. The WAC data considered in combination with the waste classification
outlined in Section 12.0 allows the most suitable waste category to be applied to the material tested. The
applicable waste categories are summarised in Table 2. A summary of the WAC data is presented in
Appendix 5. The waste category assigned to each sample is summarised in Table 3.
6
Free from equates to less than 2%.
7
HazWasteOnLineTM Tool.
All samples were assessed in terms of waste classification using the HazWasteOnLineTM tool and also the
WAC set out in Council Decision 2003/33/EC and the IMS specific WAC to give a final waste categorisation
to determine the most appropriate disposal route for any waste generated. The final and most applicable
waste category for each sample is summarised in Table 3.
Sample ID Sample Depth (m) Material Type Waste Category LoW Code
TP-01 0.00-1.00 Clay A 17 05 04
TP-02 0.00-1.00 Clay A 17 05 04
TP-02 1.00-2.00 Clay A 17 05 04
TP-02 2.00-3.00 Clay A 17 05 04
TP-03 0.00-1.00 Clay A 17 05 04
TP-03 1.00-2.00 Clay A 17 05 04
TP-04 0.00-1.00 Clay A 17 05 04
TP-05 1.00-2.00 Clay A 17 05 04
TP-05 2.00-3.00 Clay A 17 05 04
TP-05 3.00-3.50 Clay A 17 05 04
TP-06 0.00-1.00 Clay A 17 05 04
TP-06 1.00-2.00 Clay A 17 05 04
TP-06 2.00-3.10 Clay A 17 05 04
TP-07 1.00-2.00 Clay A 17 05 04
TP-07 2.00-3.00 Clay A 17 05 04
Sample ID Sample Depth (m) Material Type Waste Category LoW Code
TP-07 3.00-3.30 Clay A 17 05 04
TP-08 0.00-1.00 Clay A 17 05 04
TP-08 1.00-2.00 Clay A 17 05 04
TP-09 1.00-2.00 Clay A 17 05 04
TP-09 2.00-3.00 Clay A 17 05 04
TP-09 3.00-3.30 Clay A 17 05 04
TP-10 1.00-2.00 Clay A 17 05 04
TP-10 2.00-3.00 Clay A 17 05 04
TP-10 3.00-3.20 Clay A 17 05 04
TP-11 1.00-2.00 Clay A 17 05 04
TP-11 2.00-3.00 Clay A 17 05 04
TP-11 3.00-3.40 Clay A 17 05 04
TP-12 0.00-1.00 Clay A 17 05 04
TP-12 1.00-2.00 Clay A 17 05 04
TP-12 2.00-3.00 Clay A 17 05 04
Based on the analysis of the samples collected from the on-site excavations the material sampled is free
of contamination (PAHs, TPH, asbestos etc.). The material sampled was comprised of natural subsoils
which were free of anthropogenic materials. Following an appraisal of the chemical analysis and the
absence of anthropogenic materials the subsoils sampled are suitable for removal from site as a by-product
which will not lead to overall adverse environmental or human health impacts. If the material is to be
removed as a by-product then the producer of the by-product must demonstrate that all four criteria outlined
in Section 9 have been satisfied.
The conclusions and recommendations given and opinions expressed in this report are based on the
findings of the site investigation works and laboratory testing undertaken. Where any opinion is expressed
on the classification of material between site investigations locations, this is for guidance only and no liability
can be accepted for its accuracy. No responsibility can be accepted for conditions which have not been
revealed by the findings at the site investigation locations.
14.1. Conclusions
Based on the results of the HazWasteOnLineTM tool the material sampled across the site can be classified
as non-hazardous.
The most applicable waste category for each of the samples has been presented in Table 3, in all cases
the samples have been classified as Category A indicating that the subsoils across the site if excavated
and removed for disposal can be considered to be Category A.
14.1.3. Asbestos
The material sampled is suitable for removal from site as a by-product which will not lead to overall adverse
environmental or human health impacts.
14.2. Recommendations
In the event that material is excavated for removal from site, any firm engaged to transport waste material
from site and the operator of any waste facility that will accept subsoils excavated from this site should be
furnished with, at a minimum, copies of the full unabridged laboratory reports and HazWasteOnLineTM
report for all samples presented in this report.
The material on site if excavated and removed as a waste it should be removed to the most appropriate
facility under the waste categories and LoW codes identified in Table 3. Potential outlets for the various
waste categories are presented in Appendix 6, this list is not exhaustive and applicable at the time of the
writing this report.
The material across the site if excavated should be removed from site to an appropriate facility under either
the LoW code 17 05 04 or 17 09 04. Where during excavation there is noted to be in excess of 2%
anthropogenic material the appropriate LoW code which should be applied is 17 09 04. The most
appropriate LoW code based on the site investigation observations and testing is 17 05 04.
The material sampled is suitable from an environmental impact perspective for removal from site as a by-
product in line with Article 27 of the European Communities (Waste Directive) Regulations 2011. The
material may only be declared a by-product if all four by-product conditions are met.
b) the soil and stone can be used directly without any further processing other than normal industrial
practice;
c) the soil and stone is produced as an integral part of a production process; and
d) further use is lawful in that the soil and stone fulfils all relevant requirements for the specific use
and will not lead to overall adverse environmental or human health impacts.
15.0 References
Environment Agency (2013). Waste Sampling and Testing for Disposal to Landfill. Available at:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/321207/Sampling_and_test
ing_of_waste_for_landfill.pdf
Environment Agency (2015). Technical Guidance WM3 - Guidance on the classification and assessment
of waste (1st edition 2015) Technical Guidance WM3. Available at:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/427077/LIT_10121.pdf
Environmental Protection Agency (EPA) (2014). Letter to Licences Re: Waste Classification & Haz Waste
On-LineTM. Available at:
https://www.hazwasteonline.com/marketing/media/downloads/EPA%20Waste%20classification%20comm
unication%2020may14.pdf
Environmental Protection Agency (EPA) (2015). Waste Classification List of Waste & Determining if
Waste is Hazardous or Non-hazardous. Available at:
https://www.epa.ie/pubs/reports/waste/stats/wasteclassification/EPA_Waste_Classification_2015_Web.pd
f
Environmental Protection Agency (EPA) (2017). Draft Guidance Note on Soil Recovery Waste Acceptance
Criteria. Available at: http://www.epa.ie/pubs/consultation/soilrecoveryconsultation/
Environmental Protection Agency (EPA) (June 2019). Guidance on Soil and Stone By-products in the
context of article 27 of the European Communities (Waste Directive) Regulations 2011 Version 3. Available
at: https://www.epa.ie/pubs/advice/waste/product/Guidance_on_Soil_and_Stone_By_Product.pdf
Association of Geotechnical and Geoenvironmental Specialists (2019). Waste Classification for Soils – A
Practitioners Guide.